Title of document Delicensing of the GEHC Cardiff Nuclear Licensed Site Assessment of licensee’s delicensing application Project Assessment Report ONR-SDFW-PAR-19-016 Revision 0 3 December 2019 Template Ref: ONR-DOC-TEMP-005 Revision 12 Page 1 of 11 Report ONR-SDFW-PAR-19-016 TRIM Ref: 2019/338728 © Office for Nuclear Regulation, 2020] If you wish to reuse this information visit www.onr.org.uk/copyright for details. Published 01/2020 For published documents, the electronic copy on the ONR website remains the most current publicly available version and copying or printing renders this document uncontrolled. Office for Nuclear Regulation Page 2 of 11 Report ONR-SDFW-PAR-19-016 TRIM Ref: 2019/338728 EXECUTIVE SUMMARY Delicensing of the Cardiff Nuclear Licensed Site Permission Requested] The licensee, GE Healthcare Limited (GEHC) has requested in a letter to the Office for Nuclear Regulation (ONR) dated 26th September 2019 that the nuclear site licence (38C) for the Cardiff Nuclear Licensed Site (CNLS) within the Maynard Centre is revoked, and that the period of responsibility under that licence is ended (this process is known as ‘delicensing’). In support of its request the licensee has submitted an application pack (delicensing safety case) to ONR as evidence in support of its claim to have met the requirement of section 5(3) of the Nuclear Installations Act 1965 that in it its opinion there has ceased to be any danger from ionising radiations from anything on the licensed site. Background The licensee, GEHC, owns and operates two licensed sites under the Nuclear Installations Act 1965: one in England in Amersham, Buckinghamshire (the Grove Centre); and the CNLS. GEHC has operated these licensed sites since its acquisition of Amersham plc in April 2004. Until April 2010 the Maynard Centre manufactured radio-chemicals for the healthcare and life sciences research markets. The principal radionuclides used, in terms of radioactivity throughputs and inventories, were tritium and carbon-14, originally produced in nuclear reactors located elsewhere. Radiochemical manufacturing ceased at the Maynard Centre in 2010. In April 2015 ONR revoked site licence 38B as it agreed that GEHC had met the “no danger criterion” for the majority of the Maynard Centre following an extensive decommissioning, remediation and sampling & assessment project. In parallel with the revocation ONR issued a replacement site licence to GEHC for the bulk storage of matter on what remained of the original licensed site, (Site Licence No. 38C). The reduced licensed site, known as the Cardiff Nuclear Licensed Site (CNLS), consisted of an Intermediate Level Waste (ILW) store and a number of small ancillary buildings including two other waste stores. The site has also housed an effluent treatment plant, known as the Liquid Handling Centre, which had been decommissioned and removed prior to the replacement site licence being issued. The ILW store contained two waste types: miscellaneous wastes containing or contaminated by either tritium or carbon 14. In 2016 GEHC implemented a project to remove all waste from the CNLS and to carry out a programme of work to demonstrate that the site was suitable to be delicensed. Assessment and inspection work carried out by ONR in consideration of this request ONR has carried out radiological protection assessment of GEHC’s delicensing safety case to support the application for delicensing of the CNLS. The safety case was examined and assessed by ONR and in accordance with ONR’s internal procedures, ONR commissioned independent radiological monitoring, sampling, assessment and analysis by the Public Health England. This assisted ONR’s assessment in making a judgement as to the suitability and adequacy of the licensee’s request. ONR also assessed the licensee’s arrangements for the ongoing storage of documents as required by ONR’s published guidance on delicensing existing licensed nuclear sites. The arrangements were deemed to be adequate. Office for Nuclear Regulation Page 3 of 11 Report ONR-SDFW-PAR-19-016 TRIM Ref: 2019/338728 Matters arising from ONR's work All issues identified during ONR’s de-licensing assessment and inspection work that needed to be addressed prior to the revocation of the site licence have been resolved. Conclusions From the assessment of the licensee’s delicensing safety case and the independent verification carried out by PHE, ONR considers that there is “no danger” from ionising radiation from what remains of the Cardiff licensed site. Therefore the licensee’s period of responsibility under NIA 65 may be ended. Recommendation On the basis of the application submitted by GEHC and the conclusions set out above it is recommended that:- ONR’s Decommissioning Fuel & Waste Sites Superintending Inspector accepts this Project Assessment Report to confirm support for the ONR technical and regulatory arguments that justify the revocation of the nuclear site licence for the Cardiff nuclear licensed site. ONR’s Chief Nuclear Inspector revokes nuclear site licence number 38C for the Cardiff nuclear licensed site thereby giving effect to ONR’s opinion that there has ceased to be any danger from ionising radiations from anything remaining on the site. Office for Nuclear Regulation Page 4 of 11 Report ONR-SDFW-PAR-19-016 TRIM Ref: 2019/338728 LIST OF ABBREVIATIONS ALARP As low as reasonably practicable CNSS Civil Nuclear Security & Safeguards (ONR) CNLS Cardiff nuclear licensed site GEHC GE Healthcare Limited HOW2 (Office for Nuclear Regulation) Business Management System HSE Health and Safety Executive ILW Intermediate Level Waste NIA65 Nuclear Installations Act 1965 NSL Nuclear site licence ONR Office for Nuclear Regulation PHE Public Health England RP Radiological Protection Office for Nuclear Regulation Page 5 of 11 Report ONR-SDFW-PAR-19-016 TRIM Ref: 2019/338728 TABLE OF CONTENTS 1 PERMISSION REQUESTED ............................................................................................. 7 2 BACKGROUND ................................................................................................................. 7 3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST ............................................................................ 8 4 MATTERS ARISING FROM ONR’S WORK ..................................................................... 10 5 CONCLUSIONS .............................................................................................................. 10 6 RECOMMENDATIONS .................................................................................................... 10 7 REFERENCES ................................................................................................................ 11 Office for Nuclear Regulation Page 6 of 11 Report ONR-SDFW-PAR-19-016 TRIM Ref: 2019/338728 1 PERMISSION REQUESTED 1. The licensee, GE Healthcare Limited (GEHC) has requested in a letter to the Office for Nuclear Regulation (ONR) dated 26 September 2019 (Ref 1) that the nuclear site licence (No. 38C) for its licensed site in Cardiff (within the Maynard Centre) is revoked, and that the period of responsibility under that licence is ended. 2. The Licensee has submitted an application pack (delicensing safety case) to ONR as evidence in support of its claim, that in it its opinion, there has ceased to be any danger from ionising radiations from anything on the site or, as the case may be, on the part of it in question. 3. Section 5(1)(a) of the Nuclear Installations Act 1965 (NIA65)(Ref. 2), empowers the appropriate national authority (in this case ONR) to revoke a nuclear site license. For this to occur ONR informs the Licensee that their ‘period of responsibility’ for the nuclear licensed site is coming to an end (Section 5(14)(b)) on a certain date, only when ONR gives its opinion to the Licensee that there has ceased to be any danger from ionising radiation from the site (Section 5(15)(a)). This is known as delicensing. 4. When considering an application to delicense all or part of a licensed site, the policy statement on delicensing, “HSE Criterion for Delicensing Nuclear Sites”, (Ref. 8) specifies the requirements for enabling “no danger” under NIA65, of which the main requirements are: ‘A demonstration that any residual radioactivity above background radioactivity, which remains on the site, which may or may not have arisen from licensable activities, will lead to a risk of death to an individual using the site for any reasonably foreseeable purpose, of no greater than 1 in a million per year’. ‘a dose to an individual of 10 μSv or less per year broadly equates to the 1 in a million per year ‘no danger’ criterion and is consistent with other legislation and international advice relating to the radiological protection of the public’. ‘If an operator can demonstrate that the [ONR] criterion can be met, [ONR] may be content for the site to be removed from the requirements of the NIA65. However, the overarching requirements of the Health and Safety at Work Act, 1974, which requires operators to ensure “health and safety” so far as is reasonably practicable (or, equivalently, that risks are reduced “As Low As Reasonably Practicable” – ALARP) also apply and [ONR] will expect the operator to demonstrate that he has also considered these overarching ALARP requirements’. Note: Much of the guidance and documentation relating to delicensing was prepared when ONR’s predecessor organisations were part of the Health and Safety Executive (HSE) prior to ONR